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Alex Ottolini Alexander Aerospace, LLC. P.O. Box 681375 Franklin, TN 37068-1375 alexottolini@gmail.com
August 28, 2015
U.S. Department of Transportation Docket Operations West Building Ground Floor Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590
RE: Alexander Aerospace, LLC Petition for Exemption pursua nt to Section 333 of the FAA Modernization and Reform Act of 2012
To Whom It May Concern:
I am writing to ask that you consider my request for exemption from the following Parts of 14 CFR, per Public Law 112-95, Section 333: 21 Part H, 61.23 (a) & (c), 61.101 (e) (4) & (5), 61.113 (a), 61.315 (c) (1), (2) & (3), 91. 119, 91.121, 91.151, 91.405, 91.407, 91.409, 91.417.
Although we request exemption from the above mentioned Parts of 14 CFR, Alexander Aerospace, LLC will adhere to 14 CFR Parts 43, 45, 4 7, 61, and 91 as closely and practically as possible, even when exempt, in or der to facilitate the safest possible operations of unmanned aerial vehicles and systems. Alexander Aerospace, LLC will also follow the rules laid out in previous exemptions granted by the Administrator. We have used those exemptions , as well as the requirements outlined in Proposed 14 CFR Part 107, as a basis for our request laid out below. Regardless of our requests, Alexander Aerospace , LLC will abide by any and all requirements and limitations set forth by the Admini strator should our petition for exemption be approved.
The petition is organized as follows:

GENERAL OPERATIONS LIMITATIONS EXPLANATION OF AMENDMENTS SPECIFIC OPERATIONS AIRCRAFT CONCLUSION NOTES2

GENERAL OPERATIONS
Alexander Aerospace, LLC, subsequently referred to as AAer o in this document, will utilize small unmanned aerial vehicles and systems to carry out commercial aviation operations. Some of these operations will be similar to curr ent manned aerial vehicle operations, while others will be new utilizations o f an incredibly fast moving technology. However, the use of small unmanned systems will greatly increase safety when compared to manned aircraft operations. With a l ack of flammable fuel, operators, or passengers on board, and the small size and vis ual line of sight (VLOS) rules in place, risk to public safety is drastically reduced

. Certain examples of use by AAero include, but are not limited to the following: photography and videography for private or commercial enti ties, land survey / mapping / plotting, agricultural assessments, wildlife tr acking, and search and rescue / emergency response.

LIMITATIONS
As per acceptance by the FAA of recent Petitions of Exemption, the following list includes, but is not limited to, operational limitations th at will be adhered to:

• Operations will be limited to sUAV’s / sUAS’s weighing less than 55 pounds including payload.

• The UA may not be operated at a speed exceeding 87 knots (100 mi les per hour). Use of groundspeed or calibrated airspeed to determi ne the 87 knot speed restriction will be complied with. In no case will the U A be operated at airspeeds greater than the maximum UA operating airspeed re commended by the aircraft manufacturer.

• The UA will be operated at an altitude of no more than 400 feet a bove ground level (AGL). Altitude must be reported in feet AGL.

• The UA will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision una ided by any device other than corrective lenses, as specified on the PIC ’s FAA-issued airman medical certificate or U.S. driver’s license.

• All operations may utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC or VO at all ti mes. A VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate ve rbally at all times; electronic messaging or texting is not permitted dur ing flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that,3 if utilized, the VO can perform the duties required of the VO. ( This requirement has been amended, referencing rules listed in Proposed 14 CFR Part 107. See NOTE 1 at the end of this section. )

• An exemption and all documents needed to operate the UAS and c onduct its operations in accordance with the conditions and limitatio ns stated in a grant of exemption, will hereinafter be referred to as the op erating documents. The operating documents must be accessible duri ng UAS operations and made available to the Administrator upon req uest. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its opera ting documents. The operator may update or revise its operating documents. I t is the operator’s responsibility to track such revisions and pres ent updated and revised documents to the Administrator or any law enforceme nt official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to a grant of exemption . If the operator determines that any update or revision would affect the basi s upon which the FAA granted an exemption, then the operator must petition fo r an amendment to its grant of exemption. The FAA’s UAS Integrati on Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

• Any UAS that has undergone maintenance or alterations that a ffect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to co nducting further operations under this exemption. Functional test flights m ay only be conducted by a PIC with an optional VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

• The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

• Prior to each flight, the PIC must conduct a pre-flight inspe ction and determine the UAS is in a condition for safe flight. The pre-f light inspection must account for all potential discrepancies, e.g., inoper able components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is foun d to be in a condition for safe flight.4

• The operator must follow the UAS manufacturer’s maintenanc e, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

• Each UAS operated under an exemption must comply with all man ufacturer safety bulletins.

• Under a grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certifi cate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a te rritory, a possession, or the Federal government. The PIC must also mee t the flight review requirements specified in 14 CFR § 61.56 in an aircraf t in which the PIC is rated on his or her pilot certificate.

• The operator will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent w ith how the UAS will be operated under an exemption, including evasive and e mergency maneuvers and maintaining appropriate distances from pers ons, vessels, vehicles and structures. PIC qualification flight hours an d currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated un der an exemption are permitted under the terms of an exemption. How ever, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-b uilding flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance fro m nonparticipants in accordance with 14 CFR § 91.119.

• UAS operations will not be conducted during night, as define d in 14 CFR § 1.1. All operations will be conducted under visual meteorologic al conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

• The UA may not operate within 5 nautical miles of an airport re ference point (ARP) as denoted in the current FAA Airport/Facility Direct ory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, u nless a letter of agreement with that airport’s management is obtained or oth erwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Adm inistrator or any law enforcement official upon request.5

• The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

• If the UAS loses communications or loses its GPS signal, the U A must return to a pre-determined location within the private or controll ed-access property.

• The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

• The PIC is prohibited from beginning a flight unless (consid ering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 20% of the total flight time available, depending on aircraft conf iguration, or with the reserve power recommended by the manufacturer if greater. ( This requirement has been amended, requesting that the Administrator take into consideration the different payload configurations of dif ferent aircraft and the effects these configurations have on power usage, and allow a variable application of reserve power time limits based upon these con figurations. See NOTE 2 at the end of this section. )

• Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO- issued COA. The exemption holder may apply for a new or amended COA if it inten ds to conduct operations that cannot be conducted under the terms of the attached COA.

• All aircraft operated in accordance with this exemption mus t be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 C FR part 45, Subpart C. Markings must be as large as practicable.

• Documents used by the operator to ensure the safe operation a nd flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.2 03 must be available to the PIC at the Ground Control Station of the UA S any time the aircraft is operating. These documents must be made availab le to the Administrator or any law enforcement official upon request

.

• The UA must remain clear and give way to all manned aviation op erations and activities at all times.

• The UAS may not be operated by the PIC from any moving device or vehicle that is operating in excess of 50 miles per hour. ( This requirement has been amended, requesting that the Administrator take into consi deration operations from suitable watercraft or land vehicles, provided said operations follow6 already set forth for clearances from, distances from, and p rotection of nonparticipating persons. See NOTE 3 at the end of this section. )

• All Flight operations must be conducted at least 500 feet fro m all nonparticipating persons, vessels, vehicles, and structu res unless: a. Barriers or structures are present that sufficiently pro tect nonparticipating persons from the UA and/or debris in the ev ent of an accident. The operator must ensure that nonparticipating p ersons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structu res has granted permission for operating closer to those objects an d the PIC has made a safety assessment of the risk of operating closer t o those objects and determined that it does not present an undue haza rd. c. Flight operations may be conducted closer than 500 feet from nonparticipating persons consenting to be involved, but neve r operated directly overhead of anyone not directly involved in the opera tion. (This requirement has been amended, requesting that the Administrator take into consideration nonparticipating persons that consent to involvement. See NOTE 4 at the end of this section.)
The PIC, VO, operator trainees or essential persons are not c onsidered nonparticipating persons under this exemption.

• All operations shall be conducted over private or controlle d-access property with permission from the property owner/controller or auth orized representative. Permission from property owner/controll er or authorized representative will be obtained for each flight to be conduc ted.

• Any incident, accident, or flight operation that transgres ses the lateral or vertical boundaries of the operational area as defined by th e applicable COA must be reported to the FAA's UAS Integration Office (AFS−80 ) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site : www.ntsb.gov

. If this exemption permits operations for the purpose of clos ed-set motion picture and television filming and production, the following additional conditions and limitations apply.

• The operator must have a motion picture and television opera tions manual (MPTOM) as documented in this grant of exemption.7

• At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the loc al Flight Standards District Office (FSDO) with jurisdiction over th e area of proposed filming. The 3-day notification may be waived with the concu rrence of the FSDO. The plan of activities must include at least the follow ing: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial fil ming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on- scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aer ial filming; f. A statement that the operator has obtained permission fro m property owners and/or local officials to conduct the filmi ng production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or di agrams of any area, city, town, county, and/or state over which filmin g will be conducted and the altitudes essential to accomplish the ope ration.

• Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the film ing production, as specified in the exemption holder’s MPTOM.

• Unless otherwise specified in this grant of exemption, the U AS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.
Explanations of amendments listed above
(NOTE 1) Visual Observer: Per Proposed 14 CFR Part 107, a visu al observer may be used, but is not required.
(NOTE 2) Power Reserves: This amendment requests the Admini strator take into account the varying time of flight of different UAS platforms and payload configurations. In order to accurately assess power reserv es, every combination of platform and payload available to AAero will be flight tes ted and timed to determine proper power reserves are available prior to comm ercial operation. Ground stations used will also include power reserve indica tions.8

(NOTE 3) Operation from Moving Devices: While it will be unco mmon, the opportunity may arise where operation from a moving vehicle might be requested or necessary. When this operation poses no additi onal risk to the public, such as taking place over a large, unpopulated body o f water or area of land, AAero requests permission to assess the safety of the s ituation and make the determination regarding operation from a moving device . Current rules in regards to clearances from, distances from, and protection of nonparticipating persons, and requirements for consent, will be followed.
(NOTE 4) “Nonparticipating Persons: Persons not directly i nvolved with the operation of the UAS, but that can consent to involvement with the product of the operation.” This will allow operations nearer than 500 f eet to nonparticipating persons at an event that involves a group o f people that consent to involvement. This is ultimately a request for exe mption from 14 CFR 91.119 (a), (b), and (c) for operations involving consentin g nonparticipating persons.

SPECIFIC OPERATIONS
All AAero operations will be overseen, directly or indirectly, by company owner and founder Alex Ottolini. Alex is a certified Private Pilot and is a professional Airframe & Powerplant Mechanic, with over six years and 4000 hours mai ntaining and troubleshooting multiple makes and models of highly comple x turbine engines and turbine engine systems. He currently works for a Part 145 rep air station ensuring FAR compliance and performing administrative functions. H e has also flown and been involved with both manned and unmanned aerial vehicles for fifteen years.
Commercial and training flight operations will be conducte d explicitly within the requirements and limitations set forth by applicable FARs a nd the Administrator. Should an exemption be granted to Alexander Aerospace, LLC, registration of UAs and an application for applicable civil COAs will commence. Training requirements, PIC currency, personnel requirements, and all other requir ed operational processes will be documented and stored, and will be available for insp ection upon a reasonable request by the Administrator, an authorized rep resentative of the National Transportation Safety Board, or any Federal, State, or local law enforcement officer. Specific uses of AAero UAs will includ e:

 photography and videography for private or commercial entities

 land survey / mapping / plotting

 agricultural assessments

 damage assessment for insurance

 wildlife / livestock tracking or search and locate

 search and rescue / emergency response (only at the request of a public agency, and only if the Administrator will approve quick res ponse operations)9

This list should not be considered complete, and the rate at which the UAV and UAS industry is progressing will determine new uses and researc h by AAero. However, any commercial operation not listed here, and found to be within the operational capabilities of AAero, will be submitted as a request for ame ndment to a granted Petition of Exemption, should AAero be approved.
The specific uses listed above are largely derived from the l ocation from which we base our operations. Living in central Tennessee, we have ac cess to a large agricultural region of the country. Assessing crop needs, a nd being able to aid in search and location of livestock are ideas we want to pursue. To the east of us, mountainous terrain creates an opportunity to use UAVs in pl ace of manned aircraft in multiple scenarios, from marketing and sales to information and research, reducing costs for customers while extending their own pote ntial revenue. The number of visitors to the Great Smoky Mountains National Par k, and the potential for assistance needed in search and location, are other driving factors. The same region could benefit from wildlife tracking and assessments. Apart from specific locations, all areas are susceptible to natural disaster. U AVs can aid in information gathering and search and rescue where neither people on foot nor manned aircraft can safely survey the damage. The list goes on, but we want to p rovide a clearer picture of our business direction.
AAero maintenance operations will be conducted in the spiri t of the maintenance requirements set forth in 14 CFR Part 43 and Part 91, Subpart E , as applicable. This will be done to ensure the safety of the nonparticipating pub lic, the safety of those who hire AAero for our services, and the safety of AAero opera tions personnel. Maintenance will be logged, flight times and cycles of major components calculated, and determinations of maintenance and preventative mainte nance needed will be made and evaluated as more information presents itself. AAe ro will also adhere to manufacturers’ Safety Bulletins, Recommended or Alert Service Bulletins, Airworthiness Directives, or any other manufacturer or FAA required maintenance publications. We intend to work closely with manufacturers , relaying pertinent information from the field to help improve quality, reliabi lity, and safety, and to inform the manufacturers of any issues that need to be addres sed. All individuals working for AAero will be responsible for upholding these standards of operation.
AAero and the aircraft they own will be insured, and will have in effect liability insurance coverage that at a minimum meets or exceeds the min imum motor vehicle insurance coverages for both property damage and bodily inj ury required in the state in which the operation occurs. The coverage will be spe cific to small unmanned aerial vehicles and systems.
Safety is a critical concern to AAero. Small unmanned aerial vehicles , when used in comparable capacities to manned aircraft, will inherently pose a much smaller threat to the general public. The very nature of small UAS’s creates this result. A lack of flammable fuels needed for most sUAS’s, especially when considering quantities, is a major factor in the increase of safety. On-b oard systems technology10

is advancing at an incredible pace, and even current systems provide for a very large margin of safety in unforeseen circumstances. When all of th ese things are coupled with the regulations that are and will be put in place by the FAA, using sUAS’s in place of large manned aircraft for similar commercial missi ons will simply be safer. It is understood, however, that the ultimate responsibility will rest with the operator, and AAero will strive to be an example regarding re gulatory compliance.
Public privacy is of the utmost importance to AAero. No opera tions in surveillance or unwanted photography or videography of people or property will be carried out. Any incidental inclusion of non-consenting persons into in formation gained will not be submitted for commercial use.

AIRCRAFT
Alexander Aerospace, LLC will utilize the following aircra ft for our operations:

• DJI Spreading Wings S1000 (octocopter)

o Operating frequency between 2.4 and 2.483 GHz

o Operating weight of approximately 15 lbs

o Approximately 42 ” in diameter, approximately 15 ” in height

• DJI F550 (hexacopter)

o Operating frequency between 2.4 and 2.483 GHz

o Operating weight of approximately 5 lbs

o Approximately 24 ” in diameter, approximately 9 ” in height

• Quest Q200 (fixed wing)

o Operating frequency between 2.4 and 2.483 GHz

o Operating weight of approximately 7 lbs

o Wingspan approximately 58 ”

CONCLUSION
In conclusion, Alexander Aerospace, LLC respectfully peti tions for exemption from the current FARs previously listed. It is not the intent of AA ero to be held unaccountable by requesting exemption, but to allow AAero t o begin business as a commercial operator of small unmanned aerial vehicles and s ystems, and to become an example by which to operate under guidance from the FAA. Th e FAA has a sizable and important task at hand, developing and implemen ting the safe operation of said aircraft and systems into the National Airspace Syst em. AAero requests permission to be a part of that task.
This petition for exemption was composed using the followin g petitions and FAA acceptance letters as examples:

 Exemption No. 12009, Regulatory Docket No. FAA–2015-1466

 Exemption No. 11954, Regulatory Docket No. FAA

– 2015

– 1402

 Exemption No. 11172A, Regulatory Docket No. FAA-2014-078711

Thank you for your consideration.
Regards,

Alex Ottolini CEO & Founder Alexander Aerospace, LLC